Modern Slavery & Human Trafficking Statement

INTRODUCTION

This statement is made pursuant to section 54, Part 6 of the UK’s Modern Slavery Act 2015 (the Act). The statement sets out the steps that Rimes has taken and our commitment to improving our practices to ensure that slavery and human trafficking is not taking place in our supply chains or any parts of our business. The Act and our publishing of this statement is intended to help clients and suppliers to make better, more informed choices about the products and services they purchase and the companies they support or with whom they do business. Rimes is committed to acting ethically and with integrity in all its business dealings and relationships and ensuring that it is not involved, directly or indirectly, in the commission or facilitation of modern slavery and human trafficking, or any additional offences set out in the Act. Rimes also expects its staff, business partners and supply chains to apply the same high standard, and to take reasonable steps to ensure other parties they do business with maintain the same high standards.

OUR BUSINESS

Rimes is a longstanding provider of financial data management solutions and investment data services, serving a global client base for over 25 years. We have approximately 400 staff and we operate across major financial centres, with offices in the United Kingdom, United States, Canada, Cyprus, France, Singapore, Australia, and the Philippines. Our staff in this context include our employees and any contractors engaged by us on a full-time basis.

OUR SUPPLY CHAINS

We are a business-to-business organization and we enter into individual contracts with each of our clients  to provide bespoke services to them.

We obtain and procure goods and services from various suppliers and business partners, predominantly based in the USA, EU, UK, and to a lesser extent Asia-Pacific.   Our key suppliers are data providers, software vendors, along with information technology (including information security) suppliers. We also engage suppliers that support our corporate operations, such as office providers and suppliers providing marketing, financial, legal and compliance services. These services are provided on a contractual basis that reflects our commercial and operational requirements. We do not manufacture physical goods, nor do we operate distribution channels for physical products.

As part of our commitment to continuous improvement, we are reviewing and refining the way we assess and engage with our suppliers. We are strengthening our approach to supplier risk categorisation by developing enhanced criteria for identifying and monitoring key suppliers whose role is essential to the continuity of our services. This work forms part of our broader commitment to building greater visibility across our supply chain.

DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING

As part of our initiative to identify and mitigate risk in this area, we carry out appropriate vendor due diligence, taking a risk-based approach when entering into business relationships with partners and suppliers.  This may include making requests of prospective suppliers to complete a selfassessment due diligence check, the extent of the checks being proportionate to and dependent on the assessed risk level of the supplier.  This self-assessment due diligence compliance check will typically require information relating to that supplier’s compliance with the requirements of the Act (or equivalent legislation in their jurisdiction), including details of any required or voluntary modern slavery statements, its relevant policies and confirmation that it has programme in place to ensure modern slavery and human trafficking does not exist in its business or supply chain.

In addition, where a supplier confirms it is required to make its own statement in accordance with the Act, or confirms to us that its does so voluntarily, Rimes will review the content of the statements published.

We have also started to introduce specific contractual obligations relating to the prevention and mitigation of modern slavery risks in our vendor contracts on a risk assessed basis.

OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING

Rimes is committed to ensuring that it is not involved, directly or indirectly, for any reason, in the commission or facilitation of modern slavery and human trafficking. We maintain internal policies and procedures designed to uphold ethical conduct across all aspects of our operations and supply chains.

Our Code of Conduct reflects our commitment to acting ethically and with integrity in all our business relationships, to implement effective controls and processes, and apply a risk-based approach in seeking reasonable assurance that our business partners and/or supply chains are not involved in the commission or facilitation of modern slavery or human trafficking. Our Code of Conduct sets out the ethical and professional standards expected of all employees and our contractors/suppliers. It includes guidance on responsible business practices, legal compliance, and the prevention of modern slavery and human trafficking. It outlines our expectation that all staff, as well as our business partners and suppliers, maintain high standards of behaviour and take reasonable steps to ensure that modern slavery is not present in any business activity or relationship connected to Rimes.

Our Code of Conduct includes a whistleblowing policy which encourages and empowers our staff to identify and disclose details of any suspected modern slavery or human trafficking, either within our business practices, or within the business practices of our business partners or in any of our supply chains.

The Code of Conduct is available to our staff using our intranet sites and staff are encouraged to familiarize themselves with it as part of their employment.   All employees are required to complete annual mandatory training on the Code of Conduct, which includes guidance on ethical behaviour, anti-slavery standards, and how to recognise and respond to potential red flags. The Code is accessible at all times via our internal systems and is referenced during onboarding and policy refreshers.

In addition to the Code of Conduct, Rimes is guided by a set of internal principles that are embedded within our policies and practices to support the prevention of modern slavery and human trafficking. These include:

• We recruit staff either directly or through trusted recruitment partners, ensuring that all employment is freely chosen.
• Our internal policies reflect a zero-tolerance approach to any form of harassment, violence, or discrimination, fostering a respectful and inclusive working environment.
• We do not employ individuals under the legal minimum working age, in line with national laws and international standards.

Our policies are formally reviewed at least annually, or more frequently when there are regulatory updates or significant operational changes.

Looking ahead, we remain committed to continually improving our internal governance and awareness efforts, including strengthening staff training and regularly assessing the effectiveness of our processes to ensure they remain fit for purpose.

TRAINING AND OUR STAFF

In addition to the mandatory annual training on our Code of Conduct, we provide dedicated training on the requirements of the Modern Slavery Act as part of our compulsory staff induction and ongoing compliance training program. This training applies to all our staff, including executives and is designed to encourage our staff to be vigilant to the risks of modern slavery and human trafficking and take action where appropriate and necessary. Completion of this training is mandatory, and our Human Resources team actively monitors compliance to ensure all employees complete it within the required timeframe.

Our Human Resources team also have the responsibility to monitor and show that Rimes’ own staff are recruited and treated within the confines of local laws and regulations, and are not a victim of any modern slavery or human trafficking offences arising from their employment.

TARGETS AND UPDATES 

Our key targets for this year are to ensure all our staff have completed the dedicated training regarding the risks of modern slavery and human trafficking and to refine our vendor risk assessment criteria and procedures for storing vendor risk assessments and supporting documentation.

We will update this statement annually to reflect improvements in our processes identified over the year and latest good practice and guidance.

APPROVAL

This statement is made pursuant to section 54(1) of the UK’s Modern Slavery Act 2015 and constitutes our modern slavery and human trafficking statement for the financial year ending 31 December 2025.

This statement was approved by the Board of Directors and has been signed on behalf of the Board by Donal Smith, Chairman.

January 2026